Hawthorne Army Depot - Executive Summary

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1.  Accidental Release Prevention and Emergency Response Policies: 
 
Hawthorne Army Depot (HWAD) is a Government Owned Contract Operated (GOCO) facility.  Day and Zimmermann Hawthorne Corporation (DZHC) is the contractor for HWAD.  DZHC, handles chlorine, propane, and isopropylamine in amounts which are considered to be hazardous by the U.S. Environmental Protection Agency (EPA). 
 
It is DZHC's policy to comply with all local, State, and Federal rules and regulations.  Safety and environmental concerns are a high priority for DZHC, therefore, DZHC has its own emergency responders for the HWAD.  There is a mutual aid agreement between DZHC's emergency responders and the local emergency responders (Hawthorne Volunteer Fire Department and Mineral County Emergency Response Team). 
 
The accidental release, prevention, and emergency response policies are a unified approach that integrate technologies, procedures, and management practices.  The emergency response policy includes a response plan  
specific to the particular processes.  DZHC provides training to its employees as well as emergency responders in the following disciplines; the National Fire Protection Association (NFPA), Occupational Safety and Health Association (OSHA), Hazardous Materials (HazMat), Hazardous Communications (HazComm), and Hazardous Waste Operations and Emergency Response (HAZWOPER), Level 3 Technician training coarse specifically for the emergency responders, Level 5 Incident Scene Commanders specifically for the emergency responders, and regular fire and emergency drills specifically for the emergency responders. 
 
 
2.  The Stationary Sources and Regulated Substances Handled: 
 
DZHC has six processes that are subject to the RMP Rule.   
 
  Chlorine is used to decontaminate the drinking water used at the HWAD.  There are a total of 4,300 pounds of chlorine located at the Black Beauty Reservoir at any given time which are stored in two 2,000 pound tanks and two 150 pound cylinders. 
 
  Propane is used 
to heat the residential housing units located in the Industrial Area of HWAD.  There are a total of 253,352 pounds or 31,669 gallons of propane located near the golf course in the Industrial Area of HWAD at any given time which are stored in one 30,000 gallon tank and four empty additional tanks.  The 30,000 gallon tank is used to heat the housing area located on the HWAD.  The additional tanks total potential release is 1,669 gallons.  These tanks are used for incidental processes when needed on the HWAD.  Because these tanks are not in use they are stored near the 30,000 gallon tank for safety and convenience. 
 
  Isopropylamine is derived from the demilitarization of ammunition and is located at the 117-12 building in the Western Area Demilitarization Facility (WADF).  There can be a maximum total of 10,102 pounds of isopropylamine located in this ammunition storage building. 
 
  Isopropylamine is derived from the demilitarization of ammunition and is located at the 116-45 building 
.  There can be a maximum total of 13,177 pounds of isopropylamine located in this ammunition storage building. 
 
  Isopropylamine is derived from the demilitarization of ammunition and is located at the 116-44 building.  There can be a maximum total of 13,177 pounds of isopropylamine located in this ammunition storage building. 
 
  Isopropylamine is derived from the demilitarization of ammunition and is located at the 106-23 building.  There can be a maximum total of 15,812 pounds of isopropylamine located in this ammunition storage building. 
 
Access to all of these sites is restricted to authorized facility employees, management personnel and contractors. 
 
 
3.  The Worst Case Release Scenarios and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario: 
 
EPA's RMP*Comp Ver 1.06 was used to define the worst case and alternate case scenarios. 
 
Worst Case Scenario Chlorine - Dropping a 2,000 pound chl 
orine tank resulting in an explosion that causes the second 2,000 pound chlorine tank to rupture as well as the two 150 pound chlorine tanks would result in 4,300 pound release of chlorine.  Chlorine tanks are delivered to this facility approximately 80% full as an industry standard.  This allows for vapor expansion in varying weather conditions.  It is assumed that the entire contents of the tanks are released.  The distance to the endpoint of 1 psi is 3.4 miles.  This release has the possibility of extending beyond the facility boundary.  The affected population is 188 which are located at the family housing on the HWAD. 
 
Alternate Case Scenario Chlorine - A 1.25 inch hole in the liquid space of the 2,000 pound chlorine tank causes the chlorine to travel to the lower flammability limit.  It is assumed that the entire contents of all of the tanks are released. The distance to the endpoint for the lower flammability limit is 1.8 miles.  The affected population is 188 which are located  
at the family housing on the HWAD. 
 
Worst Case Scenario Propane - Storage of four 80% full propane tanks and a failure of the 30,000 gallon propane tank, filled to 80% in a vapor cloud explosion would release 253,352 pounds of propane.  Propane tanks are filled on this facility approximately 80% as an industry standard.  This is to allow for vapor expansion in varying weather conditions.  It is assumed that the entire contents of the tanks are released.  The distance to the endpoint of 1 psi is 0.5 miles.  The affected population is zero. 
 
Alternate Case Scenario Propane - A vapor cloud explosion of the propane tanks travels to the lower flammability limit.  This distance to the endpoint for the lower flammability limit is 0.7 miles.  The conservative affected population is 188 people located at the family housing on the HWAD. 
 
Worst Case Scenario for the Isopropylamine located at 117-12 - Lightning striking a round of ammunition with isopropylamine so that a vapor cloud explosion woul 
d release 10,102 pounds of isopropylamine.  It is assumed that the entire contents are released.  The distance to the endpoint of 1 psi is 0.2 miles.  The affected population is zero. 
 
Alternate Case Scenario for the Isopropylamine located at 117-12 - A vapor cloud fire of the isopropylamine travels to the lower flammability limit.  This distance to the endpoint for the lower flammability limit is less than 0.1 miles. The affected population is zero. 
 
Worst Case Scenario for the Isopropylamine located at 116-45 - Lightning striking a round of ammunition with isopropylamine so that a vapor cloud explosion would release 13,177 pounds of isopropylamine.  It is assumed that the entire contents are released.  The distance to the endpoint of 1 psi is 0.2 miles.  The affected population is zero. 
 
Alternate Case Scenario for the Isopropylamine located at 116-45 - A vapor cloud fire of the isopropylamine travels to the lower flammability limit.  This distance to the endpoint for the lower flamm 
ability limit is less than 0.1 miles. The affected population is zero. 
 
Worst Case Scenario for the Isopropylamine located at 116-44 - Lightning striking a round of ammunition with isopropylamine so that a vapor cloud explosion would release 13,177 pounds of isopropylamine.  It is assumed that the entire contents are released.  The distance to the endpoint of 1 psi is 0.2 miles.  The affected population is zero. 
 
Alternate Case Scenario for the Isopropylamine located at 116-44 - A vapor cloud fire of the isopropylamine travels to the lower flammability limit.  This distance to the endpoint for the lower flammability limit is less than 0.1 miles. The affected population is zero. 
 
Worst Case Scenario for the Isopropylamine located at 106-23 -A fire starting affecting a drum of isopropylamine so that a vapor cloud explosion would release 15,812 pounds of isopropylamine.  It is assumed that the entire contents are released.  The distance to the endpoint of 1 psi is 0.2 miles.  The affected 
population is zero. 
 
Alternate Case Scenario for the Isopropylamine located at 106-23 - A vapor cloud fire of the isopropylamine travels to the lower flammability limit.  This distance to the endpoint for the lower flammability limit is less than 0.1 miles. The affected population is zero. 
 
 
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps: 
 
Chlorine - There is a Process Safety Management program and a Hazard Analysis Program in place. 
Operator training - Operators are trained in self contained breathing apparatus.  Annual seminars are attended for continued education to maintain certification of operating a drinking water system using chlorine disinfection.  Operators are certified in potable water disinfection by the State of Nevada.  Operators are HazMat and HazComm trained as required by EPA and they have had OSHA training.  Operators are also trained to assist emergency responders as needed.  
 
Preventive Maintenance Program- There is a preve 
ntative maintenance (PM) program in place to minimize the chance of accidental releases due to equipment failure.  As part of the PM program there are audible alarms that are relayed to the guard operation center and monitored 24 hours a day.  There are daily visual checks and readings, weekly maintenance to all chlorine monitoring equipment, and all alarm systems are checked on a monthly basis.  In addition, all chlorine tubing heads are rebuilt and replaced annually and all tubing is replaced annually to prevent any leaks. 
 
Accurate and Effective Operating Procedures - There are complete sets of operating procedures in place.  The procedures address normal operations, as well as steps to be taken during upset conditions and safety precautions to be observed during all operational phases. 
 
Periodic Hazard Reviews of Equipment and Procedures- The hazard reviews of equipment and procedures are on an annual basis and when major physical changes are made to the process. 
 
Auditing and Insp 
ection Program - The chlorine tanks are provided by a commercial source.  The commercial source inspects the tanks prior to delivery to the HWAD.  Tanks are visually inspected as they arrive at the HWAD by the operators authorized to remove and install the chlorine tanks.  These tanks are replaced every thirty to ninety days.  The chlorination building is also inspected daily.  The State of Nevada has inspected the chlorination facility and was impressed with the alarm system technology for chlorine leak detection. 
 
Physical Security - HWAD is a physically secure facility.  Access to the chlorinator is controlled on a posted military installation.  The chlorine is inside a locked building and access is controlled by operational personnel only.  The area is also monitored by roving security guards. 
 
Propane 
Operator training - All maintenance personnel receive HazComm and HazMat training as required by EPA and they have had OSHA training. 
 
Preventive Maintenance Program - There is a pre 
ventative maintenance (PM) program in place to minimize the chance of accidental releases due to equipment failure.  Propane tanks are "real installed property" (not mobile) and are maintained through a PM program on an annual basis.  Tasks include any minor repairs and checking for the following: piping above and underground for leaks and loose connections; valves for leaks; any corrosion; any wear; any damage; any defects and mis-alignments; regulators for leaks and loose connections; any debris; tank identification; any rust and paint if necessary. 
 
 
Accurate and Effective Operating Procedures - There are no real operating procedures for the propane tanks; only maintenance procedures.  There is only an "on" or "off" position for the tanks and the empty tanks are not connected. 
 
Periodic Hazard Reviews of Equipment and Procedures - The hazard reviews of equipment and procedures are on an annual basis and when major physical changes are made to the process. 
 
Auditing and Inspection Pr 
ogram - The tanks are inspected upon each delivery by the commercial provider of propane.  They are also visually inspected semi-annually.  The meter on the 30,000 gallon tank is inspected by the State of Nevada, annually.  The empty tanks are not connected or metered. 
 
Physical Security - HWAD is a physically secure military facility.  It has a limited access area that is controlled by a security badge system and access rosters.  The propane tanks are inside a locked chain link fence and access is controlled by operational personnel.  The area is also monitored by roving security guards. 
 
Isopropylamine at 117-12 - There is a Process Safety Management program in place. 
 
Operator training - All operational personnel have completed courses in storage procedures, HazMat and HazComm training as required by EPA and they have had OSHA training. 
 
Preventive Maintenance Program - The magazines are checked on an annual basis for cracks, serviceability, and any defects that can be repaired.  An 
earth covered inspection is also completed on an annual basis.  In addition the munition conveyance air is tested for presence of isopropylamine prior to off loading into the magazine. 
 
Accurate and Effective Operating Procedures - There are complete sets of operating procedures in place.  The procedures address normal operations, as well as steps to be taken during upset conditions and safety precautions to be observed during all operational phases. 
 
Periodic Hazard Reviews of Equipment and Procedures - There are monthly meetings to discuss hazards of equipment and procedures.  There is a daily inspection of the material handling equipment used in this building.  The hazard reviews of equipment and procedures are on an annual basis and when major physical changes are made to the process. 
 
Auditing and Inspection Program - The State of Nevada inspects this building on a quarterly basis.  There were no problems observed during the last inspection in May 1999.  Quality Control and Quali 
ty Assurance personnel that are authorized, monitor these buildings and operations on a daily basis.  Also, the Defense Threat Reduction Agency (DTRA) and the Organization for the Prohibition of Chemical Weapons (OPCW) check the quantities received with their accounts, daily. 
 
Physical Security - HWAD is a physically secure military facility.  It has a limited access area that is controlled by a security badge system and access rosters.  The WADF area is physically secure inside the already physically secure HWAD facility.  All entrants that enter WADF must pass through an additional security gate.  The 117-12 ammunition magazine is locked and only those authorized are allowed to enter.  The area is also monitored by roving security guards. 
 
Isopropylamine at 116-45 - There is a Process Safety Management program in place. 
 
Operator training - All operational personnel have completed courses in storage procedures, HazMat and HazComm training as required by EPA and they have had OSHA tra 
ining. 
 
Preventive Maintenance Program - The magazines are checked on an annual basis for cracks, serviceability, and any defects that can be repaired.  (Electronics are checked every six months, pest control is activated every four years, and painters inspect the magazine every seven years.)  An earth covered inspection is also completed on an annual basis.  In addition the munition conveyance air is tested for presence of isopropylamine prior to off loading into the magazine.   
 
Accurate and Effective Operating Procedures - There are complete sets of operating procedures in place.  The procedures address normal operations, as well as steps to be taken during upset conditions and safety precautions to be observed during all operational phases. 
 
Periodic Hazard Reviews of Equipment and Procedures - There are monthly meetings to discuss hazards of equipment and procedures.  There is a daily inspection of the material handling equipment used in this building.  The hazard reviews of equip 
ment and procedures are on an annual basis and when major physical changes are made to the process. 
 
Auditing and Inspection Program - The State of Nevada inspects this building on a quarterly basis.  There were no problems observed during the last inspection in May 1999.  Quality Control and Quality Assurance personnel that are authorized, monitor these buildings and operations on a daily basis.  Also, the Defense Threat Reduction Agency (DTRA) and the Organization for the Prohibition of Chemical Weapons (OPCW) check the quantities received with their accounts, daily. 
 
Physical Security - HWAD is a physically secure military facility.  It has a limited access area that is controlled by a security badge system and access rosters.  The 116-45 ammunition magazine is secured with a high security shrouded hasp and lock.  Only those authorized are allowed to enter.  The area is also monitored by roving security guards. 
 
Isopropylamine at 116-44 - There is a Process Safety Management program 
in place. 
 
Operator training - All operational personnel have completed courses in storage procedures, HazMat and HazComm training as required by EPA and they have had OSHA training. 
 
Preventive Maintenance Program - The magazines are checked on an annual basis for cracks, serviceability, and any defects that can be repaired.  Electronics are checked every six months, pest control is activated every four years, and painters inspect the magazine every seven years.  An earth covered inspection is also completed on an annual basis.  In addition the munition conveyance air is tested for presence of isopropylamine prior to off loading into the magazine.   
 
Accurate and Effective Operating Procedures - There are complete sets of operating procedures in place.  The procedures address normal operations, as well as steps to be taken during upset conditions and safety precautions to be observed during all operational phases. 
 
Periodic Hazard Reviews of Equipment and Procedures - There are month 
ly meetings to discuss hazards of equipment and procedures.  There is a daily inspection of the material handling equipment used in this building.  The hazard reviews of equipment and procedures are on an annual basis and when major physical changes are made to the process. 
 
Auditing and Inspection Program - The State of Nevada inspects this building on a quarterly basis.  There were no problems observed during the last inspection in May 1999.  Quality Control and Quality Assurance personnel that are authorized, monitor these buildings and operations on a daily basis.  Also, the Defense Threat Reduction Agency (DTRA) and the Organization for the Prohibition of Chemical Weapons (OPCW) check the quantities received with their accounts, daily. 
 
Physical Security - HWAD is a physically secure military facility.  It has a limited access area that is controlled by a security badge system and access rosters.  The 116-44 ammunition magazine is secured with a high security shrouded hasp and loc 
k.  Only those authorized are allowed to enter.  The area is also monitored by roving security guards. 
 
Isopropylamine at 106-23 - There is a Process Safety Management program in place. 
Operator training - Operators are HazMat, HazComm, and HAZWOPER trained as required by EPA and they have had OSHA training.  Operators are also trained to assist emergency responders as needed.  HazMat Training on the regulations of US Department of Transportation (DOT) regarding the safe and legal transport of material designated as hazardous; Hazardous Material and Waste Generator Compliance as required by EPA; Safety Security & Environmental Awareness Training; DOT Hazardous Material Requirements for Department of Defense (DOD); Avoiding the most common mistakes in waste identification, generator issues, advanced RCRA topics, RCRA land disposal restrictions training; Hazardous Material Chemistry; Quality Assurance; Defense Hazardous Material Waste Handling, General Awareness, Operations, RCRA, HM181- 
126F and Safety Training; Material handling equipment (OSHA); Personal Protection and Safety Course (OSHA), one of the operators is a certified trainer for HAZMAT. 
 
Preventive Maintenance Program - Drums are inspected weekly for leaks. The magazine is checked on an annual basis for cracks, serviceability, and any defects that can be repaired. 
 
Accurate, Effective Operating Procedures - There are complete sets of operating procedures in place.  The procedures address normal operations, as well as steps to be taken during upset conditions and safety precautions to be observed during all operational phases. 
 
Periodic Hazard Reviews of Equipment and Procedures - There is a daily inspection of the material handling equipment used in this building. 
 
Auditing and Inspection Program - The State of Nevada inspects this facility on a quarterly basis.  There were no problems observed during the last inspection on 25 May 1999. 
 
Physical Security - HWAD is a physically secure military facility; it  
has a limited access area that is controlled by a security badge system and access rosters.  The 106-23 above ground warehouse is secured with a high security shrouded hasp and lock and only those authorized are allowed to enter.  The area is also monitored by roving security guards. 
 
 
5.  Five Year Accident History: 
 
No accidental releases of chlorine, propane, or isopropylamine, as defined by the RMP Rule, have occurred over the past five years. 
 
 
6.  The Emergency Response Program: 
 
DZHC has an effective emergency response program and team to ensure quick response in the event of any hazardous release.  The DZHC Fire Department includes a staff of 23, and operates on alternating 24 hours sifts of seven people each with a Fire Chief and one Inspector working ten hour days.  All personnel are certified in both hazardous technical level 3 and confined space rescue.  Additionally, 19 staff members are certified as emergency medical technicians and six people are hazardous material level 
5 certified with one hazardous material technician level 3 instructor on board.  Also, there is an emergency response team (ERT) made of 22 volunteer employees that are trained to technician level 3.  The ERT is activated at the discretion of the incident commander.  The department has three fire engines, two ambulances, one HazMat van with trailer, and a mass casualty/incident command trailer.  The DZHC Medical Clinic is available for treatment of non-critical situations and victims can be transferred to a full-service hospital via ambulance or airlifted to a larger hospital in serious cases.  Security maintains a 24 hour dispatch center for Security and the Fire Department.  All alarms are received at the dispatch center and then dispatched to the Fire Department by pager, radio, or telephone.  All emergency responders are trained extensively in propane incidents, chlorine, and in leak control measures for chemicals. 
 
 
7.  Planned Changes to Improve Safety: 
 
DZHC is continually look 
ing for new innovative ideas for water disinfection.  The isopropylamine processes will be completed by the end of August 1999. Training of all personnel involved with these hazards will continue.  Meetings and improvement discussions will also continue as they currently are unless changes are required (i.e. the need for improvements or the discontinuation of a process).  DZHC will continue to follow local, state, and federal rules and regulations as well as our own stringent rules and regulations.  Improvements are being made to our emergency responders on the mitigation of a major incident or disaster.
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